Elizabeth Sangrey Gray and Tommy Dean Gray, Jr. v. Verna Pauline Sangrey, 428 S.W.3d 311

Sangrey sued Elizabeth and Tommy Gray to impose a constructive trust on the Jefferson house and lot, alleging a mutual understanding that the Grays would buy in their names and transfer title to Sangrey after she paid the debt.
Sangrey funded the down payment, moved into the Jefferson house, paid mortgage installments, improved the property, and fully satisfied the lien after selling her Gladewater home.
The Grays refused to transfer title and asserted defenses of limitations, laches, and the statute of frauds.
The trial court found a confidential relationship between Sangrey and Elizabeth, that Elizabeth breached fiduciary duty, and that the Grays failed to prove the transaction was fair, issuing a constructive trust in Sangrey’s favor.
On appeal, the Grays challenged the hearsay evidence, the confidential relationship finding, the sufficiency of the evidence for the relationship and trust, and whether a constructive trust could attach to Tommy’s separate interest; the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the hearsay evidence admissible to prove the trust?	Grays argue hearsay evidence should be excluded.	The appellate court need not resolve admissibility; independent evidence supports the fiduciary relationship and transaction.	Harmless error; test supported by other admissible evidence; judgment affirmed.
Did a confidential fiduciary relationship exist between Sangrey and Elizabeth?	Sangrey showed a confidential relationship based on care and control.	Elizabeth challenges the existence of a fiduciary duty.	Yes, a confidential fiduciary relationship existed.
Did the existence of a confidential relationship and the transaction support a constructive trust against Sangrey’s property interests?	The transaction and breach unjustly enriched the Grays; a constructive trust is appropriate.	The Grays did not prove fairness of the transaction; Tommy’s separate interest should not be affected.	Constructive trust affirmed against the property, including Tommy’s interest where applicable.

Crim Truck & Tractor v. Navistar Intl. Transp. Corp., 823 S.W.2d 591 (Tex. 1992) (confidential fiduciary relationships and broad scope of fiduciary duties)
Moore v. Tex. Bank & Trust Co., 595 S.W.2d 502 (Tex. 1980) (burden on fiduciary to show fairness in transactions with principal)
Rice v. Metropolitan Life Ins. Co., 324 S.W.3d 660 (Tex. App.—Fort Worth 2010) (fiduciary duty and undiscovered misconduct considerations)
Chien v. Chen, 759 S.W.2d 484 (Tex. App.—Austin 1988) (all transactions between fiduciary and principal presumptively fraudulent and void)
Smith v. Deneve, 285 S.W.3d 904 (Tex. App.—Dallas 2009) (fiduciary duties in trusted relationships)
Talley v. Howsley, 176 S.W.2d 158 (Tex. 1943) (historical articulation of constructive trust principles)
Baker Botts, L.L.P. v. Cailloux, 224 S.W.3d 723 (Tex. App.—San Antonio 2007) (constructive trust framework and equitable remedies)
Troxel v. Bishop, 201 S.W.3d 290 (Tex. App.—Dallas 2006) (tracing and unjust enrichment in constructive trusts)